Document reww9BvveJ1B3O0k3ZDX5QGVq

Bringing Cleaner Power to toe IPerto Since 1988 333 West Wacker Drive, Suite 810 Chicago, Illinois 60606 Tel: (312) 929-1970 I Fax: (312) 929-1975 www.truckandenginemanufacturers.org EPA Should Proceed With A HDOH Low NO* Rule Industry Request Deliver benefits associated with an EPA-led national HDOH low NOx rulemaking Develop an appropriate EPA rulemaking schedule Direct OTAQ to work with us and other stakeholders, including CARB Rationale for EPA Leadership Essential to achieving a national program--that is our key goal Opportunity for an EPA win-win - Streamline current regulations to achieve cost savings and spur growth - Achieve real-world NOx reductions that will contribute to ozone and PM reductions - Capitalize on broad stakeholder support - Leverage OTAQ's expertise in crafting a smart rule - Assist California's ozone attainment (60-70% of California's VMT is from out-of-state vehicles) Without EPA leadership - HD NOx will remain -30% of all transportation NOx - Substantial likelihood of multiple standards for products that operate in interstate commerce - Increased manufacturing and compliance costs; loss of competitiveness for U.S. based manufacturers Opportunity for Success Pick the low-hanging fruit: Over time EPA and CARB have added new HDOH requirements piecemeal; no comprehensive review in almost two decades. Leverage our technology to achieve reforms: An HDOH low NOx rule can provide the framework to leverage technology advancements to streamline, modernize, reform and reduce the costs of the current program. Deliver real-world reductions: An EPA-led approach can provide significant NOx reductions by refocusing emission standards from lab-based testing to real-world emission monitoring and control (while maintaining a 50-state harmonized program). Avoid pitfalls: It is essential for EPA to act to: avoid a patch-work of regulations; help those areas in need to move towards ozone attainment; reduce secondary PM emissions; maintain existing GHG/fuel efficiency standards; allow manufacturers to cost effectively develop high performing, reliable, durable, customer acceptable products that can be sold nationwide; provide manufacturers leadtime, stability and certainty. A Non Governmental Organization in Special Consultative Status with the Economic and Social Council of the United Nations Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00259373-00001